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Wednesday, August 6, 2014

Confined Space Permits – Dealing with the Paradox

Confined spaces are one of those issues in occupational
safety and health that seem to make many safety professionals take notice.
Safety professionals often list confined spaces as one of the highest risk
activities in their organizations, causing them to spend a lot of time and
resources in dealing with these risks. This makes some sense, given that
confined spaces, by their very nature, make the hazards one faces worse. OSHA
defines a confined space as any space that is large enough to get into and do work,
not designed for continuous human occupancy, and difficult ingress and egress
(i.e. hard to get in and out). If you’re in an environment that limits your
ability to escape that takes away some flexibility in your ability to protect
yourself, putting more emphasis on prevention instead of response.

In response, we require our employees who enter confined
spaces to fill out a permit. This permit is different than your typical
building permit, in that it is not something provided by the government. Instead,
the confined space permit is something that the organization fills out to
permit employees to enter a confined space (more specifically, a
permit-required confined space). This permit contains information such as the
space to be entered, the job to be done, hazards of the space, protection
measures employees must follow to safely enter the space, and rescue measures
in case things go bad.

Take a step back and think about that brief list for a
second. Don’t employees already want to identify hazards, control measures, and
rescue procedures? Essentially, don’t employees already want to be safe doing a
confined space job?

Invariably, the answer to these questions are “yes.” So why
do we need a permit then?

Well, we can say that a permit is needed because it is
required by the law or because it is a liability reducing tool. That all may be
true, but in a more optimistic sense, a confined space permit is needed because
we don’t always act in our own best interest. Why not? Well, one reason is that
we may forget about a hazard or not think to identify rescue, etc. Basically,
we need a permit because we make mistakes sometimes. In this way, a permit is a
checklist, a memory aid, something designed to help us remember things we
really want to remember anyway.

Why do we make these mistakes? Well, there’s a lot of
reasons we can point to. Sometimes there’s other stuff going on, so we’re
distracted or in a hurry, or perhaps we’re tired or frustrated, or perhaps we
think we already know all the hazards when we do not (most call that
complacency, but we’re not too crazy about that term).

A common issue with checklists, such as the confined space
permit, is that people don’t always fill them out as designed. The technical
term for this is “pencil whipping” (ok, that’s not really the technical term).
But most people have pencil whipped a checklist – i.e. they have filled out the
checklist form without actually using the checklist to check the items they
were supposed to check. In the context of confined space entry, this means they
filled out the permit, but they didn’t really think about the hazards,
controls, rescue, etc.

Why would someone pencil-whip a checklist, such as a permit?
Well, right of the bat we have to say it’s not that they don’t care about their
or other’s safety. That’s too simplistic a view. Rather, in a manner of
speaking, it’s a mistake. Usually the person is distracted or in a hurry, or
perhaps they are tired or frustrated, or perhaps they think they already know
the hazards and don’t need a permit to help them.

Wait a minute…that list looks familiar. Look at the above
paragraph, and then look two paragraphs above it. Confined space permits and
all checklists have an interesting paradox – you’re most likely to make a
mistake when you are least likely to use the thing that’s supposed to help you
not make a mistake. The time you really
don’t want to take the time to fill out the permit is likely when you need the
permit the most.

This is a bit disconcerting. How do we deal with this
paradox? Well, in general, this is an example of how human performance is more
complex than we’d like it to be. If we just give people a permit and expect
them to always fill it out as required we will be setting ourselves, and,
worse, our employees up for failure. Just telling them to comply and punishing
them when they do not won’t work. Instead, we need to help our employees deal
with this complexity through design of the work environment. This includes
traditional safety engineering, such as engineering out hazards, eliminating
confined spaces, etc. This also should include design of the work system by
helping employees deal with competing goal structures and building in a work
system that has sufficient capacity to adapt to changing work environments, as
well as making systems as error tolerant as possible.

Further, this permit paradox is an illustration that safety
is not as simple as creating a rule and expecting people to follow it. As
safety professionals we must always look closely at any interventions we propose
to ensure, as much as we can, that they do not create new blindspots, new
pathways to failure, or that limit the ability of our employees to make
informed performance adjustments to their work environment. Like so many other
things in safety, we need to be on the lookout for these unintended
consequences, or else we’ll be like the emperor, believing we’re clothed in the
robe of safety, when in reality we are as naked as the day we were born.

4 comments:

First of all, the employees entering the spaces do not fill out the permit. The entry supervisor does. And the permit can be made more valuable if the employer takes the time to develop a space-specific entry permit for each different space (or group of similar spaces). This does away with the generic fill-in-the-blank permit (with it's "non-applicable" checkboxes) that tend to get pencil-whipped so often.

Thanks for the comments Curtis. I like the space-spcific idea for sure, although I still think the same human performance principles apply.

I do disagree though that the employees going in do not fill out the permit. Yes, the entry supervisor fills out the permit, but there's nothing that I'm aware of that says that cannot be the person going in the space (I could be wrong of course). Regardless, it is common practice to have the entry supervisor be someone who is doing the job. And even if it is not the person doing the job the same principles apply - the entry supervisor is more likely to make a mistake when they are less likely to fill out the permit correctly.

At my facility, the technician performing the work will complete the Pre-entry checklist portion of the permit process, typically the entrant or the attendant. This includes the pre-entry air sampling. Once complete, the per-entry checklist is reviewed by the Entry Supervisor and very often again by me, the Safety Officer. Having a second and perhaps a third set of eyes reviewing the checklist goes a long way to discourage ‘pencil whipping’. The Pre-entry checklist then becomes the notes for the pre-entry briefing, conducted by the Entry Supervisor and attended by all participants. It is not until this entire process is complete, does the Entry Supervisor sign and authorize the entry.

That sounds like an interesting process Stephen. It sounds like you have a lot of oversight on the permit process, which makes some sense. I wonder though if we can't find benefit by looking at other areas - i.e. why do people pencil-whip to begin with? Rather than simply minimizing it's effect, if we can eliminate it that would seem to be a more efficient solution.